Russia. Who and how will suspend and invalidate EAC CoC and EAC DoC in Russia from November 30, 2025?
Russia made changes to Resolution of the Government of the Russian Federation No. 936 of June 19, 2021 "On the procedure for registration, suspension, renewal, and termination of declarations of conformity, recognizing them as invalid, and the procedure for suspension, renewal, and termination of certificates of conformity, recognizing them as invalid" that came into force on June 21, 2021.
Initially Resolution No. 936 covered only certificates (CoC) and declarations (DoC) issued in Russia, however from November 30, 2025 it will also cover EAC CoC and EAC DoC issued in other EAEU member-countries (Armenia, Belarus, Kazakhstan, Kyrgyzstan) as changes to Resolution No. 936 were adopted and come into force on November 30, 2025 (Approved by Decree No. 1669 of the Government of the Russian Federation dated October 27, 2025)
From November 30, 2025, Rosaccreditation will have the authority to suspend EAC CoC and EAC DoC issued in other EAEU member-countries in case of violation of EAEU regulations.
In case EAC DoC issued on the basis of test reports from EAEU accredited test laboratories (TL) (Schemes 3d, 4d, 6d) National accreditation body (Rosaccreditation) will send a request to National accreditation body of EAEU member-country to obtain information on the status of the accreditation of the testing laboratory and information on the test report and its status.
According to the new rules EAC DoC/EAC CoC issued in other EAEU member-countries will be suspended on the territory of the Russian Federation by the state control (supervision) body in the following cases:
- the products do not comply with the requirements of the EAEU/CU technical regulations;
- the applicant (manufacture (Local representative), importer) did not provide the evidence on the basis of which EAC DoC/EAC CoC were issued (test reports);
- if Federal Customs Service (FCS of Russia) inform Rosaccreditation that there are EAC DoC/EAC CoC for which there is no information about test reports on the basis of which EAC DoC/EAC CoC were issued (test reports).
Rosaccreditation will inform Eurasian Economic Commission as well as national authorities of EAEU member-countries about the suspension and put this information in the Federal State Information System (Russia CoC/DoC register).
Rosaccreditation makes a decision to invalidate EAC DoC on the territory of the Russian Federation in the following cases:
- receipt of information from the national accreditation body of a member-country of EAEU that test report on the basis of which EAC DoC was registered, was not issued (doesn’t exist);
- conducting testing in a non-accredited testing laboratory in case declaration scheme requires it (Schemes 3d, 4d, 6d)
Rosaccreditation makes a decision to invalidate EAC СoC on the territory of the Russian Federation in the following cases:
- of failure to carry out inspection control (annual surveillance) within the established time period;
- not performing inspection control (annual surveillance) during 3 months after EAC CoC suspension.
Thus, we can come to the conclusion that if manufacture (LR), importer will comply with the following rules, EAC CoC/EAC DoC will not be suspended:
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fully comply with the requirements of EAEU/CU technical regulations;
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choose reliable certification body (CB) and accredited testing laboratory;
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check accreditation scope of CB and TL;
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ask CB and TL to provide you with the test reports;
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annually perform inspection control (annual surveillance) for EAC CoC;
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choose reliable Local representative and certification agency.
If EAC CoC and EAC DoC issued in Armenia, Belarus, Kazakhstan, Kyrgyzstan complies with all applicable rules – it will be no reason to suspend or invalidate it in Russia.
If you need approval for EAEU (EAC CoC/EAC DoC) and CIS market don't hesitate to contact us via info@imasimple.com
The information has been prepared by the IMA Simple team.
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